A political action committee's failure to disclose the source of its funding may have resulted in a county supervisor inadvertently violating campaign contribution limits, according to a longtime Orange County political watchdog.

Shirley L. Grindle, author of the county's campaign finance law, sent an email to Supervisor Janet Nguyen on Thursday, advising Nguyen to return one of the two maximum contributions she received during her 2012 bid for supervisor: a $1,700 donation from the Orange County Employees Association PAC in 2009, or a $1,700 donation from the OCEA-funded California Citizens for Fair Government political committee in 2010.

County campaign finance rules require candidates to aggregate contributions from the same funding source, and limit the total to the maximum contribution for an election cycle. The limit at the time was $1,700.

Nguyen responded with an email Friday, telling Grindle she was leaning toward returning the contributions but wanted to check with her campaign treasurer first.

Nguyen did not respond to a request from the Watchdog on Tuesday to discuss how she planned to deal with the issue.

The Watchdog reported last week that California Citizens for Fair Government failed to disclose OCEA as a “sponsor,” or the source of at least 80 percent of its funding, as required by state law. OCEA contributed the first $75,000 to establish CCFG, and provided 81 percent of the PAC's funding over its three-year lifetime, according to an Orange County Register analysis of campaign finance records. CCFG then gave its remaining $42,500 to launch a PAC with similar initials, California Citizens Fighting Government Waste.

CCFG has never identified OCEA as its sponsor. Last week, following an interview with the Register, CCFGW's treasurer updated his committee's information to disclose that it was sponsored by CCFG.

A spokesman for the Fair Political Practices Commission, which enforces state campaign finance laws, said Tuesday the reporting by CCFG is “under review.”

CCFG contributed money in 2010 to Nguyen and her political allies Tony Lam, who was running for Midway Sanitary District, and Matthew Harper, who was running for Huntington Beach City Council, according to campaign finance records. CCFGW's only donation to a political committee was an $1,800 donation in December 2012 to Nguyen's campaign for supervisor, records show.

Nguyen said in an email to the Watchdog last week that she didn't know CCFG and CCFGW were funded by OCEA, but she did not feel misled and would have accepted their contributions regardless.

The treasurer for CCFG, Chris Anderson, worked on Nguyen's 2008 campaign, Nguyen said. Anderson founded CCFG in 2009, then joined Nguyen's county staff on a part-time basis in 2010 as a district representative – a job he still holds.

Anderson was listed as a principal officer for CCFGW when it formed last year with $42,500 from the now-terminated CCFG, according to campaign finance records. The treasurer for CCFGW, David Bauer, is also Nguyen's campaign treasurer.

Nguyen said she was aware that Anderson was setting up CCFG at the time, but was not involved in the decision to set it up and did not discuss potential donors with him.

The OCEA PAC's 2009 contribution to Nguyen's campaign and the 2010 contribution her campaign received from CCFG book-end a January 2010 edict by Orange County GOP Chairman Scott Baugh that the Republican Party would no longer endorse candidates who accepted campaign contributions from unions.

Baugh's edict has forced the union to be more creative if it wants to show its support for Republican candidates, such as the GOP-endorsed Nguyen.

Rather than donating money directly to a candidate, the union turned to, among other things, independent expenditures – such as sending out its own campaign mail for a candidate and giving to other PACs, said Don Drozd, general counsel for OCEA.

Drozd said last week that he didn't recall specifics of how OCEA ended up bankrolling CCFG, but he suspected that someone approached OCEA to contribute to CCFG to support Nguyen. He didn't know who approached OCEA, but he was confident it wasn't Nguyen.

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